-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, BnYs+eCpKbt4K94+pbr7sc4uI7DvKGbD8Va/FmXhN3+ZNuNES7Q0nx8+HzFBpV5D rPJos0LtICWrwd7S4L8cxg== 0000000000-05-052016.txt : 20060322 0000000000-05-052016.hdr.sgml : 20060322 20051011135825 ACCESSION NUMBER: 0000000000-05-052016 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20051011 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: CHINA CABLE & COMMUNICATION INC CENTRAL INDEX KEY: 0000773394 STANDARD INDUSTRIAL CLASSIFICATION: CABLE & OTHER PAY TELEVISION SERVICES [4841] IRS NUMBER: 112717273 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: SUITE 805, ONE PACIFICE PLACE CITY: 88 QUEENSWAY STATE: K3 ZIP: XXXXX BUSINESS PHONE: 852 2591 1221 MAIL ADDRESS: STREET 1: SUITE 805, ONE PACIFICE PLACE CITY: 88 QUEENSWAY STATE: K3 ZIP: XXXXX FORMER COMPANY: FORMER CONFORMED NAME: CHINA CABLE & COMMUNICATIONS INC DATE OF NAME CHANGE: 20030801 FORMER COMPANY: FORMER CONFORMED NAME: NOVA INTERNATIONAL FILMS INC DATE OF NAME CHANGE: 19920703 PUBLIC REFERENCE ACCESSION NUMBER: 0001000096-05-000346 LETTER 1 filename1.txt Mail Stop 3561 October 11, 2005 Via U.S. Mail and Fax c/o Kevin Leung, Esq. (310-208-1154) Mr. Yau-Sing Tang President and Chief Financial Officer China Cable and Communications, Inc. 22 Bei Xin Cun Hou Street, Xiang Shan, Haidian District Beijing 100093, the People`s Republic of China RE: China Cable and Communications, Inc. Form 10-KSB for the fiscal year ended December 31, 2004 Filed May 16, 2005 Dear Mr. Yau-Sing Tang: We have reviewed your supplemental response letter dated August 24, 2005 as well as the above referenced filings and have the following comments. As noted in our comment letter dated June 10, 1005, we have limited our review to only the issues addressed in our letter and will make no further review of your documents. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934. Form 10-KSB for the fiscal year ended December 31, 2004 Basis of Consolidation, page F-9 1. We note your response to our prior comment # 2. We also note under Item 7.3 of your Joint Venture agreement that a number of resolutions must be passed unanimously by the board of directors. Please refer to Item 7.3 and tell us why you believe that resolution numbers 3, 4, 5 and 7 should be considered protective rights under EITF 96-16. 2. We note that as a result of the amendment to the Joint Venture agreement in 2003 you now can appoint 5 out of the 9 members of the board of directors. However, we also note in Chapter 8 of the Joint Venture Agreement that the Joint Venture should establish a joint managerial institution to be responsible for its daily operation and management. We also note that a General Manager proposed by Party A shall be in charge of the joint managerial institution. Since Party A is in charge of the Joint Venture`s daily operations, it is unclear to us how you concluded that you should control the Joint Venture. Please revise or advise in detail. Form 10-Q for the period ended June 30, 2005 Consolidated Statement of Operations and Comprehensive Income, page 4 3. It is unclear to us why you did not classify your provision for bad debts below your loss from operations. Please revise or advise. * * * * Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file your response on EDGAR. You may contact Bob Carroll, Staff Accountant, at (202) 551-3362 or Carlos Pacho, Senior Assistant Chief Accountant, at (202) 551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions. Sincerely, /s/ Kyle Moffatt for Larry Spirgel Assistant Director ?? ?? ?? ?? Mr. Yau-Sing Tang China Cable and Communications Page 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE -----END PRIVACY-ENHANCED MESSAGE-----